NSF-61 Annex G Standard
AB 1953 and NSF 61 Annex G
The official AB 1953 bill changes the meaning of term lead free
in the Health and Safety Code form eight percent lead for
pipes or pipe fittings, and four percent lead for plumbing
fittings and fixtures to a weighted average of not more than
0.25 percent lead content within each component that comes
into contact with the wetted surfaces of pipes and pipe
fittings, plumbing fittings and fixtures effective July 1,
2010. Along with this change brings new standards like the Annex G standard, the modified version of NSF / ANSI Standard 61.
NSF/ANSI Standard 61 was revised in December 2008 to establish requirements for use when a 0.25% lead content requirement needs to be met in addition to current chemical extraction requirements of the standard. The requirements were placed in Annex G - Weighted Average Lead Content Evaluation Procedure to a 0.25% Lead Requirement. In addition, mandatory language placing restrictions on the use of lead as an intentional additive in water contact materials was also added to Section 3.
A request was made to add these requirements to the standard to allow manufacturers the option of being certified to a lead content standard, such as California's Health & Safety Code (Section 116875) commonly known as AB1953. That law, which goes into effect January 1, 2010, applies to any pipe, pipe of plumbing fitting, or fixture intended to convey or dispense water for human consumption through drinking or cooking. A similar law has been enacted in Vermont and is also to take effect January 1, 2010.
The annex was developed through the Lead Task Group of the Drinking Water Additives Joint Committee and includes requirements that enable conservative and consistent application of the lead content evaluation procedure. Highlights include:
- The annex contains <0.25% weighted average lead content requirements. Compliance is determined by a weighted average calculation involving the maximum percent lead content of material specifications and wetted surface areas.
- Does not consider coatings or acid washing. Compliance is determined by the maximum percent lead content of material specification for each component prior to application of any coatings or lead wash treatments. Documents including an opinion from East Bay Municipal District and statement of legislative intent were provided to the Lead Task Group during development of the annex.
- For internally threaded products, the wetted surface area includes 25 percent of the threaded area(s). This is consistent with the assumptions used in the rest of Standard 61.
- Annex G does not contain a verification test protocol at this time as compliance is determined based on calculations using the maximum % lead content of material specification. A verification test methodology is under development for addition to Standard 61 that can be used when a there is a need or desire to verify that the actual lead content of a component is within the stated lead content of the material specification. The work being done on this verification methodology is being performed through the Lead Task Group and California's Department of Toxic Substance Control (DTSC) to establish a consistent protocol that can be used by all.
- Annex G is an optional annex under NSF/ANSI 61. Certifications to Annex G note compliance within the NSF/ANSI 61 or NSF/ANSI 14 listing.
- The annex requires full compliance with NSF/ANSI 61.
- The annex does not specifically reference California and applies to any jurisdiction with a ≤0.25% weighted average lead content requirement.